The ACT Minister for Education has released a discussion paper on the establishment of an ACT Schools Standards Authority. The proposal is to expand the function of the Board of Senior Secondary Studies to be responsible for establishing and monitoring educational standards from pre-school to Year 12. This could include teacher registration, curriculum frameworks, student achievement standards, registration of private schools and home education. The Authority could also have overarching responsibilities for monitoring the general standards of schooling in the ACT.
Some preliminary comments are outlined below to assist public discussion of the proposal.
- The proposal represents one of the biggest changes in the governance and administration of the ACT school system since it was first established. Key administrative functions will be transferred to a statutory authority.
The only comparable change was the abolition of the ACT Schools Authority Council in 1988 and even then that change did not involve such an extensive change in the administration of the system as this proposal.
- The form of the Authority and its governance arrangements are not outlined. The powers proposed for the new Authority are not indicated. For example, will it have the power to introduce compulsory syllabi in schools as in the case in NSW? Will it have the power to impose external exams for Years 10 and 12 as in NSW?
The composition of the Authority is not outlined either. Will it be a representative body, an expert body or some combination of both? Which bodies will be represented on the authority? Who will have the balance of power?
The community is being asked to consider the establishment of an Authority whose legislative and operational details are unknown.
- No clear justification for transferring functions to the new Authority is provided. No evidence is provided that the current administrative arrangements are unsatisfactory and could be better carried out in a statutory authority. Such lacunae usually indicate another, hidden, agenda.
- This is further suggested by the short period of consultation. The community is given only five weeks to discuss perhaps the biggest upheaval in the governance and administration of the school system since it was first established.
Organisations such as P&C Council will have little opportunity to formally consider the proposal and no likelihood of being able to consult with P&C Associations, let alone the broader parent community. School boards will have virtually no opportunity to discuss the proposal or canvass views in their school community.
The short time period for consultation on such a major change is an insult to the public. It appears the Minister wants to ram through the change with minimal consultation and discussion.
- The most likely reason for the change is to reduce the direct accountability of the Minister for Education for key administrative functions. The functions are removed from the direct political process and the Minister can now say it is not his/her responsibility.
- A particular concern is the removal of the registration of private schools from the direct political process. It could well undermine the new legislative arrangements by giving control over the registration process and other accountability requirements to a less accountable body where representatives of the private school sector can exert greater influence over the process than they can under the current legislation.
- The economies of scale argument is not relevant. These functions are already administered in one body. Changing them to another body will not increase economies of scale in administration.
- The only argument advanced for the change is that other states have similar statutory authorities to administer such functions. However, it is not clear, and no evidence is presented to support it, that these authorities have increased administrative efficiency and accountability to the public. In fact, in some states the private school sector has considerable control over the registration process and the accountability arrangements for private schools in receipt of government funding are minimal.